ML101810238
| ML101810238 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/2010 |
| From: | Office of Nuclear Regulatory Research |
| To: | |
| Bayssie Mekonen/RES 251-7489 | |
| Shared Package | |
| ML101800482 | List: |
| References | |
| DG-5029, RG-5.010, RG-5.015 RG-5.080 | |
| Download: ML101810238 (7) | |
Text
Staff Responses to Public Comments on Draft Regulatory Guide DG-5029 (Proposed Revision of Regulatory Guides 5.10 and 5.15)
(Public comments have been edited for clarity)
Strategic Teaming and Resource Sharing (STARS)
Integrated Regulatory Affairs Group P.O. Box 411 Burlington, Kansas 66839 (ML093521575)
E.J. Brooks Company (Brooks)
Security Products Group 8 Microlab Road Livingston, New Jersey 07039 (ML093521552)
Comments NRC Comment Resolution Originator DG-5029 Section Specific Comment NRC Staff Response STARS-1 2.2.2.2 In the third paragraph in section 2.2.2.2, a testing program should be utilized is described. If the staff believes the manufacturers testing program is not sufficient, then the wording must be specific as to the types of testing necessary.
The current wording will create confusion as to what, if anything is required. For example, phrases such as multiple attempts and significant number of attempts are subjective and open to interpretation. The Staff should state the requirements for testing and that the licensee has reviewed the manufacturers testing program for the seals and found it to be adequate or has otherwise sponsored a testing program.
The staff has reviewed and considered the comment. Regulatory guides only provide suggested methods of complying with the requirements set forth in the regulations found in Title 10 Code of Federal Regulations (10 CFR). Therefore, this regulatory guide cannot require any type of testing or specify what testing should be conducted.
This section is included to suggest that licensees evaluate the manufacturer's testing program and conduct additional tests if necessary for site-specific applications.
STARS-2 2.2.3 The second paragraph in section 2.2.3 provides suggestions that are not within the scope of the RG. The RG should not provide suggestions to the The staff reviewed the comment and revised the statement to clearly indicate that the data in question is data related to the seal and container on
12/10/2010 Page 2 licensee on control of data outside the scope of this RG. The paragraph should be deleted.
which the seal is applied. Records of seals and to which container they are attached are an integral part of the use of TIDs and PS seals and therefore fall within the scope of this regulatory guide.
STARS-3 2.2.4 Section 2.2.4 is outside the scope of this RG. The control of the recorded data is not the subject of this RG. The section should be deleted.
The staff reviewed the comment and revised the section to clearly indicate that the data in question is data related to the seal and container on which the seal is applied.
Records of seals and to which container they are attached are an integral part of the use of TIDs and PS seals and therefore fall within the scope of this regulatory guide.
STARS-4 2.4.6 The second paragraph under 2.4.6 seems to contain an optional requirement. If the desire is to get vendor verification that seal designs are protected and controlled, then the paragraph should state that explicitly. If this is only a suggestion, the paragraph should be deleted to prevent confusion between the licensee and the staff.
The staff has reviewed and considered the comment. Regulatory guides only provide suggested methods of complying with the requirements set forth in the regulations found in 10 CFR.
Therefore, all statements in this regulatory guide are suggestions and no requirements are to be set forth in any regulatory guide.
STARS-5 2.4.6.1 The last two sentences under 2.4.6.1 are ambiguous. If the decals are not acceptable for the application, then it should be stated as such. If they are acceptable, delete the The staff has revised the statement for clarification.
12/10/2010 Page 3 last two sentences.
STARS-6 2.4.6.2 The last sentence of section 2.4.6.2 should be deleted. The requirement of a company logo on a seal is beyond the scope of this RG.
The staff has reworded this section to clarify that the incorporation of a company logo is optional and may contribute to the authenticity of the seal.
STARS-7 3.2 All but the last sentence of the third paragraph under section 3.2 should be deleted. It is not appropriate for the RG to specify the organization of the licensee. The procedures and process in place are adequate.
An effective TID program requires that only authorized personnel have access to TIDs and data associated with TIDs. This paragraph describes a common acceptable practice.
Other means of organization and procedures may be acceptable as well.
Brooks-1 Multiple sections Numerous comments throughout this regulatory guide suggested the guide refer directly to the use of new technologies such as RFID, GPS, Zigbee, barcodes, and other electronic technologies.
The staff has reviewed and considered this comment. The NRC accepts barcodes for use in identifying seals and the guide has been revised to reflect this more frequently.
At the present time the NRC does not have sufficient information concerning the reliability of other new technologies such as RFID, GPS, and others to endorse their use for protection of special nuclear material. The NRC is actively studying the technology and if any use of new technology is found to be acceptable it will be noted in future revisions of this and other regulatory guides.
12/10/2010 Page 4 Brooks-2 2.2.1 Rewrite the sentence on holographic logos to include holograms and logos that are printed in UV ink.
Staff revised the statement in accordance with this suggestion.
Brooks-3 2.2.1 Specify seals should have a unique serial identification number.
This statement has been reworded to say code instead of number to include alpha-numeric combinations which are acceptable.
Brooks-4 2.2.1 Comment noted:
There can be no substitute for an effective, TID storage, inventory and accountability program in place wherever TIDs are used. The assignment of specific individuals, with clear responsibilities for the same should be an integral part of any TID program.
Staff concur with this statement and this area is addressed in Sections 3.1 and 3.2.
Brooks-5 2.2.2 Comment suggested referring to the fact that certain braided wire, cable TIDs provide pre-formed cable. When the cable is cut, wire strands individually separate, making their reinsertion within the seal body nearly impossible.
Section 2.4.5 covers specific braided wire seals and includes this information.
Brooks-6 2.2.2 Comment suggested that clear installation instructions that emphasize critical steps in installation should always be available.
Staff concur with this comment and the section has been changed to reflect this.
Brooks-7 2.2.2 State that PS seal manufacturer recommendations should be followed on what seal should be used based on the Staff concur and added this language for both PS and TID seals.
12/10/2010 Page 5 application surface conditions.
Brooks-8 2.2.2.1 Comment suggested that PS seals should be applied for 20 minutes before containers are released.
A sentence has been added to state that manufacturer recommendations for how long seals should be applied before release should be followed.
Brooks-9 2.3 In the discussion of removing remnants of voided seals from surfaces, comment suggested acknowledging that non-residue void type seals are available from some manufacturers and are typically used for applications where the user does not want to spend time removing remnants of past seals.
This comment is included here and in Section 2.4.6.1.
Brooks-10 2.4.1 While this section addresses steel padlocks, comment suggested including a reference to a conventional brass padlock with a small hole drilled through its body and shackle for TID insertion.
Staff have included this description and renamed section 2.4.1 Padlock Seals to include padlocks made of other materials.
Brooks-11 2.4.1 Comment suggested including seals that meet the requirements of ISO-17712.
The NRC is in the process of acquiring ISO standards for staff review. If staff find that ISO-17712 meets NRC requirements this will be reflected in future revisions of this regulatory guide.
Brooks-12 2.4.2 Comment suggested that E-Cup Seals are no longer a preferred choice of seal.
NRC still finds E-Cup Seals acceptable for use.
12/10/2010 Page 6 Brooks-13 2.4.4 Comment suggested a more detailed description of the fiber optic seal system.
NRC cannot endorse specific commercial products. Some additional detail has been added to this section but references to the precise number of fiber optic strands and other details that may indicate a specific brand or model of fiber optic seal are not included.
Brooks-14 2.4.5 Comment suggested that the tamper-evident wire seals metal trap be identified as an E-Cup.
This section refers to tamper-evident wire seals in general.
Section 2.4.2 discusses E-Cup type seals.
Brooks-15 2.4.5 Comment suggested referencing new types of TIDs with specific features and bar-codes laser etched in the TID.
A more generic description of these other TIDs has been incorporated into 2.4.5.
Brooks-16 2.4.6.1 Comment provided a extensive detailed description of void seal types.
This information has been included except for reference to covert seals. NRC staff have not reviewed covert seal technology sufficiently to include in this regulatory guide at this time.
Brooks-17 2.4.6.2 Comment pointed out that holograms can be imprinted directly on a void-type seal.
Section has been reworded to state that some manufacturers may be able to incorporate a hologram directly onto the seal.
Brooks-18 2.4.6.3 Comment suggested additional reference to security tapes which transfer a layer of adhesive onto the surface if removed, which is difficult to remove even with a razor blade.
Section 2.3.6.3 has been reworded to clarify that these types of security tapes are included and that the difficulty of removing a residual adhesive layer is dependent upon both the nature of the surface to which
12/10/2010 Page 7 the label is applied and the nature of the adhesive in the seal.
Brooks-19 2.4.6.5 Comment pointed out that optical chemical coatings contribute to a seals authenticity.
This comment has been included.
Brooks-20 2.4.6.5 Comment suggested including another type of chemical coating, a chemical taggent.
Section has been amended to include chemical taggents.
Brooks-21 2.5 Comment suggested that several other field-verifiable TIDs warrant serious consideration.
Validation of tamper evident labels and tape require no special tools. Simple observation of a void message within the label, or on the applications surface, should afford clear tamper evidence.
Individual strands of thinner diameter cable seals should individually come part to reveal tampering.
Use of a simple, inexpensive, hand-held bar code/
passive, RFID reader will quickly identify any irregularity when read results are compared with information collected previously.
Except for the reference to RFID readers (See Staff Response to Brooks-1), this information has been incorporated.
Brooks-22 3.2 Comment noted that consideration should be given to ease of handling and applying seals when wearing gloves.
This section has been amended to suggest licensees consider the environment in which personnel are applying TIDs, including whether or not personnel protective equipment is required.